Hi, I'm Dave Kats from Therapist Consultants, and I have a tip for you.
We talked last week about the three forms that you need to be compliant with HIPAA. It doesn't mean that if you have those three forms you'll be compliant, but without those three forms you won't be compliant.
There's another thing you have to have and that is a HIPAA manual. I think that everybody pretty much has a HIPAA manual, and if you don't, you certainly have to get one right away to be in compliance with HIPAA.
The HIPAA manual actually talks about your HIPAA program – how you're going to keep patients' information private. So you need to have a HIPAA manual. But the HIPAA manual isn't the dead document. You don't just run one-off photocopy and put it in a 3-ring binder, and then never visit it again. Even if you use somebody else's template, you have to personalize it, and then every once in a while, you have to go through an update to your HIPAA manual.
There are a lot of forms in a HIPAA manual that you have to keep current. For instance, if you have employees and you train those employees, you have to have those employees sign that they've been trained. There are other things. You have to have a compliance officer. Even if you are the compliance officer, you have to write your name on a form that says you're the compliance officer, and you have to keep the log of your compliance officers.
There are lots of other things you have to have down, too. For instance, you have to have a log of all your electronic equipment that keeps patient records. You have to have their model and their serial number, and you have to keep track of them. Also, when you retire them, you have to write down how you retired them out of use. You can't just shut it off and give it to your little cousin to play with. It has the patients’ records still in it.
There are lots of things you have to do to update your HIPAA manual on a regular basis. Here's what I do. In the week between Christmas and New Year's, I do all my custodial work for the practice. I go through an update to whole HIPAA manual at that time. I retrain the staff at that time on HIPAA projects, and then I feel like I'm safe throughout the year as long as I retrain anybody that I hired during the year.
Here's what I suggest you do. Wait till the week between Christmas and New Year's. At the week between Christmas and New Year's, get that HIPAA manual out, dust it off, bring it up to date, and you'll be glad that you did.
This is Dave Kats. Thanks for listening.
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